CIR vs P&G

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P&G declared dividends payable to P&G USA

- to the amount of Php 24.1M

P&G paid 35% dividend withholding tax

- amounted to 8.3M
- claimed for tax credit, dapat 15% lang daw dapat

ISSUE:
1) WON P&G PH is entitled to refund or credit?

SC - Yes!

US Internal Revenue Code, Sec 902:

- a domestic (US) corp owning 10% of remitting foreign corp shall be deemed to have
paid a proportionate extent of taxes paid by such non-US corp upon remittance of
dividends to US corp